Glen Campbell died yesterday. He was truly an American original. He grew up dirt poor, as a sharecropper’s son, near Delight (pronounced DEE-light), Arkansas and went onto to achieve worldwide fame. While many will remember him as the Rhinestone Cowboy, my fondest memories of Campbell are from the 60s when he was one of the top Los Angeles studio musicians. According to his New York Times (NYT) obituary, Campbell “provided accompaniment for a host of famous artists, including Frank Sinatra, Dean Martin, Nat King Cole, Elvis Presley, Rick Nelson and groups like the Beach Boys and the Mamas and the Papas.” He toured as a Beach Boy, substituting for Brian Wilson who was in one of his early dark periods.

He came to television prominence when he appeared as a guest performer on the Smothers Brothers summer show and was later given his own TV variety show. He appeared as a Texas Ranger in the Oscar winning film, True Grit, alongside John Wayne and Kim Darby. Campbell had his own battles with drugs and alcohol, some very public. Perhaps his most enduring non-musical legacy will be his very public struggle with Alzheimer’s disease. He had announced publicly in 2011 he had the disease. His final movie was a documentary, Glen Campbell: I’ll Be Me, about his struggles through the condition to make his final tour. It was tough to watch.

It was Campbell’s release of this final information which informs today’s post. By letting go of the private condition of Alzheimer’s disease, Campbell helped to not only shed light on this disease but also helped others whose loved ones struggle with the condition. Sometimes it really is better to let go. Adam Bryant wrote about this in a recent NYT Corner Office column where he profiled Lyft President John Zimmer, in a piece entitled “‘Empowering’ Means Truly Letting Go. Zimmer had some interesting insights which I thought applied for the Chief Compliance Officer (CCO) or compliance practitioner.

One of Zimmer’s earliest leadership lessons was the need for empathy, which he feels “is the most important trait for a manager. It probably comes from the mentality of hotel management, which is that you have to understand every job you’re managing, so you spend time doing things like washing dishes and housekeeping.” Channeling his inner-Atticus Finch, Zimmer went on to observe, “If you’re going to manage people or lead people, you have to be able to walk in their shoes and understand them.”

One of the key cultural values at Lyft is to literally “be yourself” as Zimmer feels that it is important an employee feel comfortable at work. Zimmer had begun his professional career at Lehman Brothers, where he most decidedly did not feel comfortable or be himself. So he has striven to bring that value to Lyft. As a CCO or compliance professional, this is one thing you should continually strive for, to have employees feel comfortable with your compliance program and the personnel in your compliance department so they will come to you when an issue arises.

As a leader, Zimmer faced the challenges of many business start-ups in the area of scalability. He said the company went from 30 employees to over 1700 quite quickly. He admitted he made many mistakes but the importance for Zimmer was that he learned from these mistakes. One of the biggest lessons was around hiring. Zimmer said, “The most important thing I’ve found is to know your weaknesses and hire people better than you. That takes a certain amount of confidence. I remember hiring folks with way more experience than me and feeling very unsure of my ability to lead them. The answer is to lead with values and vision.”

Every CCO should study those concepts and put them into practice. I have seen many corporate lawyers who were afraid of those who outworked them and had other skills they lacked. As a leader, you simply cannot afford such myopic views. Understand your weakness and build your team to compensate for them to increase the overall strength of your compliance team. It will only increase your compliance program as well.

Inevitably, Bryant asked questions about Uber and the very different cultural models in the two companies. Zimmer’s response was insightful for the CCO or compliance professional. He said, “I used to be distracted by them a lot more in the early days, when I wasn’t as confident in the idea that we need to just focus on our values and who we are. More recently, I’ve embraced the idea that we can control what we can control, and that’s the focus now.” Zimmer’s bottom line is to not be distracted and focus on what you can control.

Consider this from the compliance perspective around the highest perceived risk under the Foreign Corrupt Practices Act (FCPA); that being third parties. If you cannot have a full five-step process for the lifecycle management of third parties and are constrained with a step then more fully utilize another of the steps. It may mean more robust management of third parties after the contract is signed to make sure they are delivering services for the value you are paying them. However, this type of approach may well satisfy the regulators should the Department of Justice (DOJ) or Securities and Exchange Commission (SEC) come knocking.

In the area of management feedback, Zimmer has received some interesting comments. He said, “I’ve gotten feedback about getting in the weeds. There’s a difference between saying you’re empowering someone and really empowering them by letting them also grow as a leader and not always being there. Sometimes you have to just let people grow and make mistakes on their own.” As a CCO you have to let you team make some mistakes so they can grow. This is often difficult (particularly if you have made the same mistake) but critical for the professional growth of your compliance team.Bryant ended his piece on Zimmer by asking him to provide career advice for college graduates. I found it be an excellent catch phrase for every compliance practitioner “Know your values and stay true to them.” He then went on to add, “Those things are really simple, but there are so many distractions and there’s so much technology in our faces that people aren’t necessarily following those rules.” Perhaps you should consider this message for your compliance training.

To listen to a YouTube performance of the Wichita Lineman, click here.



This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at

© Thomas R. Fox, 2017